Fidel Hernandez v. State of Florida

CourtDistrict Court of Appeal of Florida
DecidedJune 10, 2026
Docket3D2024-0173
StatusPublished

This text of Fidel Hernandez v. State of Florida (Fidel Hernandez v. State of Florida) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fidel Hernandez v. State of Florida, (Fla. Ct. App. 2026).

Opinion

Third District Court of Appeal State of Florida

Opinion filed June 10, 2026. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D24-0173 Lower Tribunal No. F23-5362 ________________

Fidel Hernandez, Appellant,

vs.

State of Florida, Appellee.

An Appeal from the Circuit Court for Miami-Dade County, Laura María González-Marqués, Judge.

Carlos J. Martinez, Public Defender, and Nicholas A. Lynch, Assistant Public Defender, for appellant.

James Uthmeier, Attorney General, and Kayla Heather McNabb, Assistant Attorney General, for appellee.

Before FERNANDEZ, MILLER and BOKOR, JJ.

BOKOR, J. Fidel Hernandez, the defendant in a domestic battery case, appeals

the trial court’s denial of a peremptory challenge attempting to strike a female

juror. The trial court found that the defense used the peremptory in a

discriminatory way and that their gender-neutral explanation was not

genuine. For the reasons explained below, we conclude that a proper

application of the Melbourne factors to the record mandates reversal.

BACKGROUND

Hernandez was charged with assault with a deadly weapon and

domestic battery by strangulation, to which he pled not guilty and requested

a jury trial. During jury selection, the court used a randomized process by

addressing jurors in order from a list prepared beforehand by a judicial

assistant. The juror at issue here, number 34, was the defense’s fourth

attempted peremptory challenge.

At the beginning of jury selection, the parties initially stipulated to

exclude two male jurors for cause. The State then made a cause challenge

to a female juror, number 31, which the defense opposed. The court denied

that challenge, and the State used its first peremptory on juror 31, over the

defense’s objection. The parties then accepted two male jurors, struck one

female juror by stipulation, struck another female juror after a cause

challenge from the defense, and accepted the next female juror without

2 objection. The defense used their first peremptory on a male juror, number

17, without objection, and then challenged another male juror, number 39,

for cause, arguing that he did not appear to understand the burdens of proof.

The court denied that cause challenge, leading the defense to use their

second peremptory on juror number 39.

Next, the defense then attempted to use their third peremptory to strike

juror 22, a Hispanic woman. The State requested a race- and gender-neutral

explanation, and the defense explained that the juror was shaking her head

during questioning and did not appear to understand the court’s instructions.

The court found this explanation to not be genuine and denied the challenge,

though the court did not indicate whether the challenge was improper due to

racial or gender grounds.

Finally, the defense then attempted to exercise another peremptory on

juror number 34. The State objected solely on gender-related grounds, and

defense counsel explained that they were concerned about the juror’s

response to a question about conflicts of evidence and that “it just didn’t

seem to me like she understood that aspect.” Relying solely on the defense’s

previous attempt to strike juror 22, the court found this explanation pretextual

as well and again denied the peremptory. Both jurors were ultimately seated

3 and returned a guilty verdict. Hernandez now appeals, alleging that the court

abused its discretion by denying the peremptory challenge to juror 34.

ANALYSIS

When ruling on a challenge to a party’s exercise of a peremptory strike,

the trial court must apply the three-step process set forth in Melbourne v.

State, 679 So. 2d 759, 764 (Fla. 1996). This analysis starts with the opposing

party making a timely objection, showing that the venireperson is a member

of a distinct group, and requesting that the court “ask the striking party its

reason for the strike” (step 1). Id. Upon completion of step 1, the court must

ask the proponent of the strike to provide a race-neutral explanation (step 2).

Id. “If the explanation is facially race-neutral and the court believes that, given

all the circumstances surrounding the strike, the explanation is not a pretext,

the strike will be sustained (step 3).” Id. (footnotes omitted). Importantly,

“[t]he court’s focus in step 3 is not on the reasonableness of the explanation

but rather its genuineness. Throughout this process, the burden of

persuasion never leaves the opponent of the strike to prove purposeful racial

discrimination.” Id. (footnote omitted); see also Welch v. State, 992 So. 2d

206, 211–12 (Fla. 2008) (applying Melbourne standard and test to claims of

gender discrimination in the context of a peremptory challenge).

4 The Florida Supreme Court has explained that “peremptory challenges

are presumed to be exercised in a nondiscriminatory manner and . . . the

appropriate standard of appellate review for determining the threshold

question of whether there is a likelihood of [protected class] discrimination in

the use of peremptory challenges is abuse of discretion.” Nowell v. State,

998 So. 2d 597, 602 (Fla. 2008). “Notwithstanding this deferential standard,

however, a trial court’s determination that a strike is pretextual will be

reversed by the appellate court if there is no record support for the trial

court’s finding.” Brannon v. State, 320 So. 3d 898, 902 (Fla. 3d DCA 2021).

“While this Court has made it clear that Melbourne does not require a trial

court to expressly articulate its thought process in making a genuineness

determination, our case law does require the record to support the trial

court’s genuineness determination.” Id. at 903 (citation omitted) (reversing

and remanding denial of peremptory where defendant only exercised one

prior peremptory strike against juror of same racial group, record did not

indicate that either strike was racially motivated, and court did not articulate

rationale to support its genuineness determination); see also Wynn v. State,

99 So. 3d 986, 989 (Fla. 3d DCA 2012) (“[I]f the explanation advanced for a

peremptory challenge is reasonable and the record is devoid of any

indication that the judge considered relevant circumstances in denying the

5 strike, an appellate court must conclude the trial judge did not engage in the

‘genuineness’ inquiry Melbourne requires.”).

In evaluating whether a facially-neutral explanation is pretextual,

“[r]elevant circumstances may include––but are not limited to––the following:

the [protected class] make–up of the venire; prior strikes exercised against

the same [protected class]; a strike based on a reason equally applicable to

an unchallenged juror; or singling the juror out for special treatment.”

Melbourne, 679 So. 2d at 764 n.8 (citing State v. Slappy, 522 So. 2d 18 (Fla.

1988)). “While prior strikes exercised against the same [protected class] is a

relevant circumstance which may be considered in determining whether the

proffered reason for the strike is genuine, the exercise of such prior strikes

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Related

State v. Slappy
522 So. 2d 18 (Supreme Court of Florida, 1988)
Melbourne v. State
679 So. 2d 759 (Supreme Court of Florida, 1996)
Nowell v. State
998 So. 2d 597 (Supreme Court of Florida, 2008)
Welch v. State
992 So. 2d 206 (Supreme Court of Florida, 2008)
Jones v. State
787 So. 2d 154 (District Court of Appeal of Florida, 2001)
Wimberly v. State
118 So. 3d 816 (District Court of Appeal of Florida, 2012)
Siegel v. State
68 So. 3d 281 (District Court of Appeal of Florida, 2011)
Wynn v. State
99 So. 3d 986 (District Court of Appeal of Florida, 2012)

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Fidel Hernandez v. State of Florida, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fidel-hernandez-v-state-of-florida-fladistctapp-2026.